Last edited 07/13/2023

Privacy Policy

1. Background

1.1        This Policy explains how we may Process your Personal Data.

1.2        This Policy is issued by Hala Systems Inc, a Delaware corporation, located at 1209 Orange Street, Wilmington, New Castle DE, United States (“Hala US”), and its related entity, Hala Systems Unipessoal Lda (Hala PT) (together, “Hala”, “our organisation” “we”, or “us”).

1.3        This policy is addressed to individuals outside our organisation with whom we interact, including individual clients, representatives of client organisations, visitors to our Sites, users of our Apps, products and other users of our services (together, “you”). Defined terms used in this Policy are explained in Section 18 below.

1.4        For the purposes of this Policy, the Hala US and Hala PT are both Controllers. Contact details for any enquiries or other correspondence relating to this Policy are provided in Section 17 below.

1.5        This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.

2. Collection of Personal Data

2.1        We may collect or obtain Personal Data about you: (i) directly from you (e.g., where you contact us); (ii) in the course of our relationship with you (e.g., if we provide services to you); (iii) when you make your Personal Data public (e.g., if you make a public post on social media); (iv) when you download, install, or use any of our Apps or products; (v) when you visit our Sites; (vi) when you register to use any of our services;  (vii) when you interact with any third party content or advertising on a Site or in an App; or (viii) or when we directly collect, process and store evidence.

2.2        We may also receive Personal Data about you from third parties (e.g., local partners in the countries in which we work) or through our work in the field of evidence collection, preservation and storage. This work includes the collection and preservation of radio signals.At the point of collection, Hala units record radio signals from a broad spectrum of radio frequencies. Selected    signals undergo a number of technical steps resulting in audio files that can be understood by the human ear. In accordance with the Best Practices, the resulting audio files will all contain human voices which may include personally identifiable information.

3. Creation of Personal Data

3.1        We may create Personal Data about you (e.g., records of your interactions with us). We may also create Personal Data about you, such as records of your communications and interactions with us, including attendance at events we hold or interviews in the course of applying for a job with us. We may record or take notes of telephone calls, meetings, and other interactions in which you are involved, in accordance with applicable law.

4. Categories of Personal Data we may Process

4.1        We may Process: (i) your personal details (e.g., your name); (ii) demographic data (e.g., your age); (iii) your contact details (e.g., your address); (iv) matter details (e.g., your instructions to us); (v) records of your consents to our Processing of your Personal Data; (vi) payment details (e.g., your billing address); (vii) information about your use of our Sites and Apps (e.g., the type of device you are using); (viii) details of your current employer; (ix) information about your interactions with our content or advertising; (x) any views or opinions you provide to us or have provided publicly; and (xi) images of you available on open source mediums; (xii) recordings of your voice collected through open source mediums.

4.2        We may Process the following categories of Personal Data about you:

a.        Personal details: given name(s); preferred name; and photograph;

b.         Demographic information: gender; date of birth / age; nationality; salutation;  title; and language preferences;

c.         Identifier information: passport or national identity number; utility provider details; or bank statements;d. Contact details: correspondence address; telephone number; email address; and details of your public social media profile(s);

e.         Attendance records: details of meetings and other events organised by or on behalf of Hala that you have attended;

f.         Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent);

g.         Payment details: billing address; payment method; bank account number or  credit card number; cardholder or account holder name; card or account security details; card ‘valid from’ date; and card expiry date; invoice records; payment records; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.

h.         Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; and other technical communications information; username; password; security login details; usage data; aggregate statistical information.

i.        Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.

j.        Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (including mouse hover, mouse clicks, any forms you complete (including incomplete forms not submitted) and any touchscreen interactions).

k.        Views and opinions: any views and opinions that you choose to send to us, or publicly post on public platforms.

l.        Images: publicly available through open source mediums.

m.        Descriptions of you publicly available through open source mediums.

n.        Recordings of your voice obtained through open source mediums.

5. Sensitive Personal Data

5.1        Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

5.2        We may have to Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

a.        Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

b.        Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

c.        Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or

d.        Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is not used in relation to Processing that we are legally required to carry out).

6. Purposes of Processing and legal bases for Processing

6.1         We Process Personal Data for the following purposes: providing our Sites, Apps, and services to our stakeholders including you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; compliance with applicable law; improving our Sites, Apps, and services; fraud prevention; and recruitment and dealing with job applications.

6.2        The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

7. Disclosure of Personal Data to third parties

7.1        We may disclose your Personal Data to other Hala entities created in the future, for legitimate business purposes (including operating our Sites and our Apps, and providing services to you), in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy.

7.2        If we engage a third party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.

7.3         In addition, we may disclose your Personal Data to:

a.        legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

b.        accountants, auditors, lawyers and other outside professional advisors to Hala, subject to binding contractual obligations of confidentiality;

c.        third party Processors (such as providers of data hosting services and document review services), located anywhere in the world, subject to the requirements noted below in this Section 8;

d.        any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;

e.        any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;

f.        any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

g.        any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

8. International transfer of Personal Data

8.1        We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses. You may request a copy of our Standard Contractual Clauses using the contact details provided in Section 17 below.

8.2        Because of the international nature of our business, we may need to transfer your Personal Data to other Hala entities, and to other third parties as noted in Section 7 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

8.3        Please note that when you transfer any Personal Data directly to a Hala entity established outside the EEA, we are not responsible for that transfer of your Personal Data (and such transfer is not based on or protected by our Standard Contractual Clauses). We will nevertheless Process your Personal Data, from the point at which we receive that data, in accordance with the provisions of this Privacy Policy.

9. Data security

9.1        We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us is sent securely.

9.2        We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

9.3        Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us is sent securely.

10. Data accuracy

10.1        We take every reasonable step to ensure that your Personal Data is kept accurate and up-to-date and is  erased or rectified if we become aware of inaccuracies.

11. Data minimisation

11.1        We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

11.2         We take every reasonable step to ensure that:

a.         Your Personal Data that we Process are accurate and, where necessary, kept up to date; and

b.         Any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

c.        From time to time we may ask you to confirm the accuracy of your Personal Data.

12. Data retention

12.1        We take every reasonable step to ensure that your Personal Data is only retained for as long as they are needed.

12.2        We take every reasonable step to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Policy.

12.3        The criteria for determining the duration for which we will keep your Personal Data is that we will retain copies of your Personal Data for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

13. Your legal rights

13.1        Under applicable law, you may have a number of rights, including:

a.        the right not to provide your Personal Data to us;

b.        the right of access to your Personal Data;

c.        the right to request rectification of inaccuracies;

d.        the right to request the erasure, or restriction of Processing, of your Personal Data;

e.         the right to object to the Processing of your Personal Data;

f        the right to have your Personal Data transferred to another Controller;

g.         the right to withdraw consent;

h.         and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.

14. Cookies and similar technologies

14.1        When you visit a Site or use an App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our Cookies Policy <ENTER COOKIE POLICY URL>

15. Legal Statements

15.1        All use of our Sites, our Apps, or our services is subject to our Legal Statements at <ENTER URL.> We recommend that you review our Legal Statements regularly, in order to review any changes we might make from time to time.

16.  Direct marketing

16.1        We may Process your Personal Data to contact you via email, telephone, or other communications formats to provide you with information regarding Hala services that may be of interest to you. You may unsubscribe for free at any time.

16.2        We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

16.3        You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

17. Contact details

17.1        If you have any comments, questions or concerns about data privacy, including the processing of personal data carried out by us, or on our behalf, please contact us by email: <legal@halasystems.com>.

18.  DEFINITIONS

18.1        "Adequate Jurisdiction" a jurisdiction that has been formally designated by the European Commission or the United Kingdom Government as providing an adequate level of protection for Personal Data.

a.        "App" means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).

b.        "Controller" means the entity that decides how and why Personal Data is Processed.

c.        "Cookie" means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a "Cookie" includes analogous technologies such as web beacons and clear GIFs.

d.         "Data Protection Authority" means an independent public authority that is tasked, by law, with overseeing compliance with applicable data protection laws.

e.        "EEA" means the European Economic Area (the Member States of the European Union, together with Norway, Liechtenstein and Iceland).

f.         "Personal Data" means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

g.         "Process", "Processing" or "Processed" means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

h.         "Processor" means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

i.         "Sensitive Personal Data" means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

j.         "Site" means any website operated, or maintained, by us or on our behalf.

k.         "Standard Contractual Clauses" means template data transfer clauses approved by the European Commission or by a Data Protection Authority for the purpose of transferring data outside of the EEA or the United Kingdom.